To Whom it may concern February 18, 2021
Response to the draft: Silvicultural Guidelines for the Ecological Matrix Lands
By Nature Nova Scotia
A first review of this document gives the impression that it is a step forward in an appropriate ecological direction. But closer examination of its decision keys, using the Forest Ecosystem Classification for Nova Scotia, revealed some serious flaws.
Under irregular shelterwood prescriptions, some forest types wind up in restorations with 80% removal of their basal area followed by the planting of long-lived, intermediate tolerant species. This could result in healthy forests being turned into softwood plantations on ecological matrix lands. That seems a deliberate contrivance and spawns, once again, a lack of trust regarding Lands and Forestry’s motives.
That fact caused this reviewer to forgo the time needed for an extensive appraisal. It’s obvious that forest harvesting remains the prime motivation here, in spite of the shift to true ecological forestry that the Lahey report recommended on two-thirds of the Crown forest base.
Nature Nova Scotia (NNS) does not have the staff or volunteer time for wading further through a document with such ingeniously disguised intent.
As a member of the Healthy Forest Coalition (HFC), NNS and NNS Vice-President Donna Crossland took part in discussions and authored much of the detailed and extensive HFC response to this forestry manual. To avoid redundancy, Nature NS adds its full approval to HFC’s in-depth assessment of this document.
Listed below are a few of nature’s needs that are inadequately addressed or not addressed at all in active forestry areas under these proposed new guidelines for the ecological matrix.
1) Until there is a full conversion from even-aged harvests that amount to clear-cutting, to healthy, uneven-aged, multispecies forests, wildlife requires 100 metre wide riparian buffers, not the present 20m. Hotter water, and with small streams and vernal pools drying up sooner because of climate change and heavy forest removals, demand change this now.
2) Following the federal Migratory Birds Convention Act, there should be no forestry activities on Crown lands over the period from May 15 – July 31 to accommodate the migratory bird breeding season. This short time period amounts to a serious and deadly compromise with early and late nesting bird species. But it would be an improvement for many species.
3) Current guidelines for protecting woodland raptor nests, such as goshawks, fail to incorporate adequate provisions for hunting territories around their nest sites. They require these habitats for successful nesting.
4) In these ecological matrix guidelines, harvests should be limited to 1% annually, with periodic interventions every several years irrespective of size. Such harvests would result in more gradual habitat changes over a longer time periods.
5) An entirely new Crown Land Act is in order to counter a capitalist industry that only attaches value to a forest when it becomes a woodpile. Other acts will need to be amended or revised for the same reason.
6) The Wildlife Act and regulations need to be adjusted and fine-tuned to better reflect species-specific wildlife habitat needs. New wildlife habitat guidelines should reflect good science and not industry/government compromises. These changes need to be applied to harvest-targeted matrix stands.
7) The manual needs to set aside more actual and potential wildlife trees per hectare.
8) This Department is still mired in the Crown land “giveaway/ money pit for private profits” game. This flies in the face of woodland owners’ abilities to get fair value for their wood. Woodland owners are part of nature and need a fair shake too.
9) The myriad of other aspects of healthy forests’ ecological, recreational and spiritual values should be incorporated into the many relevant acts and reflected better in these guidelines. Lahey suggested such a revision. Forestry for private profit on Crown land should constitute a minor aspect of healthy forest ecosystem use. The many other important aspects and human values associated with forests need a strong focus here, rather than being ignored.
10) Forestry employment is down. Forest fibre quality is disappearing. Restoring healthy forest ecosystems, not further plundering and degrading in the name of ecological forestry should be the goal.
11) Soils need replenishment, not wholesale fibre removal which is recommended on some poor sites. Too little woody debris is being left to decompose and replenish the soils for growing future forests. More nutrients are leaching from some soils than are being captured over time. Nutrient deficiencies noted in these guidelines should be given more influence in the prescriptions.
12) Our forests have been overcut. Their rate of degradation has increased in recent decades with the use of heavy machinery. Instead of an increase of fibre supplies to mills, and the development of new technically-feasible uses, Lands and Forestry should let our forests and their inhabitants have a much-needed rest. This slowdown should begin with longer rotation times that match average tree lifespans more closely and provide more wildlife habitats.
13) These guidelines demonstrate what became evident while reviewing the earlier version: Lands and Forests staff either do not possess the ability, or have the will, to enact ecological forestry. Those having a clear-cut mentality need to be purged. Department staff standing in the way of ecological forestry implementation must be set aside from this process, and nature given the opportunity to heal.
14) Nature NS repeats its call for a moratorium on forestry harvests on Crown land that create even-aged forest regeneration. This moratorium should stay in place until ecological alternatives are enacted and used by the forest industry.
15) Lands and Forestry needs to engage in landscape-scale wildlife planning and a wider perspective regarding land use planning on Crown lands. This is so overdue that it seems deliberate. The cutting that this oversight has permitted over the past decades is, in itself, an indictment against the single-mindedness of this department, and speaks loudly to its corporate capture by the forest industry.
President, Nature Nova Scotia
Member organizations: currently representing more than 10,000 citizens
Annapolis Royal and Area Environment and Ecology Group: Blomidon Naturalists Society : Cape Breton Naturalists Society : Eastern Shore Forest Watch Association : Friends of Nature: Friends of the Pugwash Estuary : Halifax Field Naturalists : Margaree Environmental Association : Stop Spraying and Clear-cutting NS: Nova Scotia Bird Society : Nova Scotia Wild Flora Society : Tusket River Environmental Protection Association :